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December 31, 2009

Andrew Arthur
15A Elm Ave
Delmar, NY 12054

dSGEIS Comments
Bureau of Oil & Gas Regulation
NYSDEC Division of Mineral Resources
625 Broadway, Third Floor
Albany, NY 12233-6500

Dear Sir or Madam:

I am writing to encourage the New York State Department of Environmental Conservation to carefully
consider the comments both pros-and-cons on expanded natural gas drilling, and modify their draft
SGEIS appropriately. In the past two years of consideration of the issues many concerns have been
raised, most importantly by the US Environmental Protection Agency (E.P.A.). The DEC should
seriously look at the E.P.A.'s thoughtful comments raised on the proposal in their “Marcellus dSGEIS
Comment Letter Plus Enclosure”, and try to integrate them into the SGEIS document.

Unlike some, I am not opposed to natural gas drilling. Indeed, I am quite skeptical of some of the
claims put forward by the anti-drilling groups. Many of them simply do not grasp basic geology, nor do
they fully consider the mostly successful record of gas and oil drilling in our state and beyond. Serious
accidents at oil and gas wells is exceedingly rare in our state, and when they happen, they mostly have
been successful remedied. That said, the US E.P.A. raises some serious concerns that must be addressed
before a final SGEIS document is released.

It may be appropriate at this time to end the horizontal drilling moratorium, as the issues surrounding it
are well known. Companies that wish to drill individual wells in the next year, should provide
individual Environmental Impact Statements and follow the full SERQA process rather then relying on
the accelerated GEIS process. At the same time, the state should push forward on getting the SGEIS
done right, so to comprehensively review the process of gas drilling for macro impacts on the state as a
whole. The EPA notes serious concerns for macro impacts of drilling, not addressed in SGEIS that are
key to getting the final document right.

As you already know, the DEC proposed a comprehensive ban on open burning in February 2008. They
announced draft rules in March 2008 and held hearings from June to August 2008. They took public
comment, and adjusted the regulations based on public concerns. They redrafted the regulations and
held a new series of hearings and took more public comment in June of 2009. They announced final
regulations in September 2009, and implemented them in October 2009. When considering such a
comprehensive policy change like natural gas drilling, a similar methodical approach makes sense.
Delays do not mean necessarily that a policy will not happen, but that it will be improved.

I believe that we as a society must look to expand our use of natural gas for electricity production, as a
cleaner alternative to coal and oil. Natural gas produces half as much carbon dioxide as coal, much less
solid waste, and a fraction of the sulfur dioxide and nitrous oxides. It will be an economic boom for the
Southern Tier. Expanded natural gas drilling will also help sustain struggling family farms and bring in
new tax revenues, much like wind farms have already done for the Northern Tier of New York.
Horizontal drilling is too important of a technology to turn our backs on, however it must be properly
administered to minimize potential environmental impacts.

That said, while natural gas drilling is a low-impact activity once wells are installed, drilling them can
cause substantial nuisance and serious accidents have the potential to create substantial pollution. We
must use caution, and prior to finalizing the SGEIS make sure all of the serious questions have been
addressed. When an agency as important as the E.P.A. asks hard questions, then it only makes sense for
the DEC to listen.

Repeal the moratorium on horizontal gas drilling, allow individual wells approved through the SEQRA
Process, and re-write the SGEIS to reflect the serious concerns of the E.P.A. and the greater public. As
required by law, allow the public to comment on a revised SGEIS and then finalize it, and allow for we


Andrew Arthur